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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`APPLE INC.,
`Petitioner,
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`v.
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`KOSS CORPORATION,
`Patent Owner.
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`Case IPR2021-00600
`Patent 10,298,451
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`PETITIONER’S UNOPPOSED MOTION TO SEAL
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`Case IPR2021-00600
`Attorney Docket No: 50095-0020IP2
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`Pursuant to 37 C.F.R. §§ 42.14 and 42.54, Petitioner Apple Inc. respectfully
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`requests the Board to authorize the filing under seal of certain filings in this case,
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`including the Joint Agreement Regarding Additional Discovery filed concurrently
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`herewith. The parties have met and conferred on this Motion, and Patent Owner
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`does not oppose.
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`Petitioner requests that the default Protective Order govern the materials in
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`this proceeding. Pursuant to the Trial Practice Guide, 77 Fed. Reg. 48,756, 48,770,
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`a copy of the acknowledgement page of the default Protective Order signed by
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`Lead Counsel of Petitioner is attached hereto as Attachment A.
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`Good cause exists to seal the Joint Agreement Regarding Additional
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`Discovery. Public disclosure of the Joint Agreement Regarding Additional
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`Discovery has the potential to significantly harm Petitioners’ competitive position
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`because it would allow competitors to access highly sensitive information
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`regarding litigation strategy and Petitioners’ financial data. For these reasons,
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`Petitioner has designated the Confidential Materials as “Protective Order Material”
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`under the default Protective Order.
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`Undersigned counsel, on behalf of Petitioner, certifies that the information
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`sought to be sealed has not, to their knowledge, been published or otherwise made
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`public by Petitioner.
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`2
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`Date: December 15, 2021
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`Case IPR2021-00600
`Attorney Docket No: 50095-0020IP2
`Respectfully submitted,
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`
`
` /W. Karl Renner/
`W. Karl Renner, Reg. No. 41,265
`Roberto Devoto, Reg. No. 55,108
`Ryan Chowdhury, Reg. No. 74,466
`Fish & Richardson P.C.
`3200 RBC Plaza, 60 South Sixth Street
`Minneapolis, MN 55402
`T: 202-783-5070
`F: 877-769-7945
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`3
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`Case IPR2021-00600
`Attorney Docket No: 50095-0020IP2
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 CFR § 42.6(e), the undersigned certifies that on December
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`15, 2021, a complete and entire copy of this Petitioner’s Unopposed Motion to Seal
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`were provided via email, to the Patent Owner by serving the correspondence
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`addresses of record as follows:
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`Mark G. Knedeisen
`Laurén Murray
`Brian P. Bozzo
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`K&L GATES LLP
`K&L Gates Center, 210 Sixth Avenue
`Pittsburgh, PA 15222
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`Email: mark.knedeisen@klgates.com
`Email: lauren.murray@klgates.com
`Email: brian.bozzo@klgates.com
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`
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`/Crena Pacheco/
`Crena Pacheco
`Fish & Richardson P.C.
`60 South Sixth Street, Suite 3200
`Minneapolis, MN 55402
`(617) 956-5938
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`Case IPR2021-00600
`Attorney Docket No: 50095-0020IP2
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`Attachment A
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`5
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`APPLE INC.,
`Petitioner,
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`v.
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`KOSS CORPORATION
`Patent Owner
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`Case IPR2021-00600
`Attorney Docket No: 50095-0020IP2
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`Case IPR2021-00600
`Patent 10,469,934
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`Standard Acknowledgment for Access to Protective Order Material
`I, W. Karl Renner, affirm that I have read the Protective Order; that I will
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`abide by its terms; that I will use the confidential information only in connection
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`with this proceeding and for no other purpose; that I will only allow access to
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`support staff who are reasonably necessary to assist me in this proceeding; that
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`prior to any disclosure to such support staff I informed or will inform them of the
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`6
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`Case IPR2021-00600
`Attorney Docket No: 50095-0020IP2
`requirements of the Protective Order; that I am personally responsible for the
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`requirements of the terms of the Protective Order and I agree to submit to the
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`jurisdiction of the Office and the United States District Court for the Eastern
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`District of Virginia for purposes of enforcing the terms of the Protective Order and
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`providing remedies for its breach.
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`Date: December 15, 2021
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` /W. Karl Renner/
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`W. Karl Renner, Reg. No. 41,265
`Fish & Richardson P.C.
`3200 RBC Plaza, 60 South Sixth Street
`Minneapolis, MN 55402
`T: 202-783-5070
`F: 877-769-7945
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`
`Attorney for Petitioner
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`7
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